On 01/30/07 07:58, Stan Prevost wrote:
"Mark Hansen" wrote in message
Now I would guess that every pilot in this situation is logging the time
as
PIC, but the statement was that a strict interpretation of the regulations
do not allow it (except that now, the legal opinion provides a way, in
that
it allows for an exception if the person operating the controls is not
"rated").



Maybe allows a way. The continued effectivity of the opinion would have to
be researched. As Dr. Rosenfeld said, it is old. Part 61 underwent a major
rewrite since that opinion, and the basis for the opinion may have changed.


I wonder if when they go about re-writing a section of the FAR if they
don't consider the legal opinions that were written for the section over
the years. I would think they may not want to incorporate the opinion
into the FAR simply because the opinion, as written, is doing its job.



--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA